In meetings at the Federal Communications Commission, the Minority Media and Telecommunications Council is raising concerns about proposed Network Neutrality rules aimed at ensuring an open Internet. MMTC is making these eight points:

Institutional neglect of minority issues at the FCC and, more recently at the Commerce Department, with the apparent failure to award minority companies any stimulus funds, explain why MMTC is cautious in its approach to network neutrality regulations and how these regulations could be applied to minorities.

In the National Organizations' Comments, they concede the first and sixth proposed regulations; they are still studying the second, third, and fourth proposed regulations, and they are troubled about aspects of the fifth proposed regulation.

Our overarching concern is closing the digital divide. Minority businesses cannot aggregate enough business without consumers adopting broadband. The FCC should undertake studies to determine the economic cost of not closing the digital divide, including the cost of second order effects.

The FCC should conduct an economic analysis and examine the proposed network neutrality regulations for their potential impact on deployment. With respect to carriers investing in deployment, if they have more money in their portfolios, the more likely they are to disburse deployment in a variety of investment risk levels to build out and improve broadband. If it is true that the regulations would make it more difficult for carriers to raise money and build out, then we need to examine the indirect effects such as increasing prices for consumers and decreasing adoption.

The FCC should bear in mind the natural business alignments for small and minority businesses. ISPs have incentives to maximize customers, whereas small businesses are in competition with the major content and application providers.

The Commission should design network management rules to allow carriers flexibility so that they can partner with and incentivize entry by SDBs and MBEs.

Ideally, full transparency combined with consumer literacy and competition could render most other network neutrality regulations unnecessary; however, consumer literacy is the weak link. MMTC has proposed to add digital literacy to the K-12 curriculum to help solve the digital literacy problem.

The Commission should brief the Commerce Department on the issues of access to capital for minority businesses and how the lack of stimulus funding for minority businesses impacts the FCC's ability to do its job in promoting diversity in telecommunications.